I decided to finally clean up an old account on CivitAI (https://civitai.com/). Nothing unusual - I just wanted to exercise my right to be forgotten, the one I heard about so much on Reddit before, being a regular lurker.
I sent them a polite email citing Article 17 GDPR. Gave them enough info to find me (email, username, first login date, payment history). Didn’t use my real name, didn’t log in - partly because I didn’t want to trigger Cloudflare’s fingerprinting again.
Their reply?
“When users delete their account, this action is permanent, since we delete any and all data associated with that account.”
Maybe? There’s no way to verify their claim without re-engaging. No public deletion policy (https://civitai.com/content/privacy). No confirmation. No alternative. Only if you log in to do it. Which means triggering Cloudflare’s tracking system again.
I shouldn’t have to expose myself to surveillance just to ask to be forgotten.
Honestly, I was taken aback a little. But fair enough, I thought. I still have a shield for myself - let’s escalate.
I filed with the Irish Data Protection Commission (DPC) - mostly because they accept anonymous, English requests.
They closed my case within days with this:
You’re from Ukraine. Not our problem.
No discussion of whether CivitAI targets EU users (they do!). No interest in the fact they process personal data globally. Didn’t even ask if I was in the EU at that time. Just a flat rejection based on my location.
Fine. Maybe NGOs can help?
I contacted:
- Access Now
- EDRi
- Digitalcourage
- epicenter.works
- Even tried the UK ICO (turns out, CivitAI blocks UK users now, so no luck there)
Out of all of them, only epicenter.works replied - twice - telling me to contact noyb.
Which is silly, because I already did. Over a month ago. Still no reply.
So here I am.
I did everything I could - correctly, thoroughly, and in good faith. But all I got in return is silence, deflection, bureaucracy.
Don’t get me wrong - I still believe in the idea of GDPR. I want to believe in it. But the enforcement? It’s a paper tiger. All bark, no bite. And worst of all, it doesn’t even have self-respect - happy to roll over the moment someone shows up without an EU passport.
This wasn’t about being petty or creating drama. I just wanted to get in control of my data, as was promised by the GDPR declaration.
But apparently, even that is too much to ask.
Anyway, vent over. Just wanted to share this so others don’t waste months chasing rainbows like I did.
And maybe - just maybe - someone at noyb, DPC, or CivitAI will finally read it and feel ashamed enough to act.
P.S. Why I’m posting it here:
- I think it fits this community topic
- This post was removed from r/gdpr by moderators
- Some subreddits ignored my request to approve this post on their subreddits
- r/privacy requires karma to post
- I was shadowbanned by Reddit for no apparent reason
- Similar post saw zero reaction on Mastodon instance
- Twitter & Bluesky requires solving a captcha that I’m incapable of solving
In addition, since the initial post on Reddit and Mastodon weeks ago, I’ve sent emails to various privacy oriented news outlets and public organizations, but I was ignored by all, but EFF which replied “we can’t help you”.
EDIT: To clarify a recurring point: GDPR does not require you to be an EU citizen or resident to be protected.
Under Article 3(2), it applies to any company that offers goods/services to people in the EU - even if the user is from Ukraine, the US, or elsewhere. if anyone think I’m in wrong, please provide source. I don’t see what I’m doing wrong here.
Proof (screenshots)
My GDPR request sent to support@.
Reasserting rights after their first refusal.
“Use the button.” No erasure guarantee.
Irish DPC closes case based on nationality.
The EU isn’t the world police. Expecting them to enforce their laws in a case where none of the involved parties are in the EU is odd.
And the GDPR isn’t a universal right, it’s a right of EU citizens. Similarly, the US’ First Amendment right to free speech won’t save you from hate speech charges in Germany. Heck, it won’t do that even if you’re a US citizen, so long as the offense is on German soil.
Fair point, and I get why it might look that way.
But here’s the thing. CivitAI doesn’t block EU users. It used EUR pricing, English (the EU’s lingua franca), their current pop-up says they’re privacy and GDPR compliant (somehow), and infrastructure that logs EU traffic (Cloudflare EU nodes). The Irish DPC is their de facto lead authority - that’s why Meta, Google, and TikTok all get fined by them.
So when they dismiss my complaint with “you’re from Ukraine” - without even asking if I was in the EU when I used the site, or whether CivitAI targets EU users - it’s not legal analysis. It’s triage. And in that triage, non-EU users get deprioritized - no matter what the law says.
I’m not arguing theory. I’m reporting what happened:
Correct, it is not a universal right. They are not engaging with you because your complaint is outside their jurisdiction. And the company isn’t either. It’s like expecting Saudi Arabia to apprehend a Dutchman in Riyadh because you showed them a photograph of him drinking alcohol in Amsterdam. Sure, he’s in their country, so they could do it. And he did something that’s illegal in their country. But he didn’t do it in their country.